Writing a submission
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3/ Cut and paste the following draft submission (please feel free to modify/ amend/ add extra details)
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For extensive analysis about why this project should not proceed, please check here.
Objections to the mining infrastructure licence application by CopperChem’s parent company WHSP Stockman Pty Ltd (Licence app no. MIN006642) may be lodged on-line at https://rram.force.com/ObjectionSubmission by April 4th.
Earth Resources Tenements
Department of Economic Development, Jobs, Transport and Resources
GPO Box 2392 Melbourne Vic 3001.
RE: Application Number MIN006642
CopperChem has applied (MIN 006642) for an infrastructure mining licence to reopen and expand the existing Tailings Storage Facility (TSF) at the Stockman mine in the catchment of the Tambo River in East Gippsland. Works will involve removal of vegetation and earthworks, construction and operation of the [enlarged] TSF, management of water and runoff, waste rock management and site rehabilitation and closure.
I strongly object to MIN 6642 mining infrastructure licence being granted for the following reasons:
1/ In 2006 it cost nearly $7 million of taxpayer funds to rehabilitate the abandoned Benambra mine tailings storage facility (TSF) and mine site, and the tailings dam area was exempted from any future mining licence. This exemption should never have been revoked or amended.
Re-opening and expanding the tailings dam jeopardises this rehabilitation work.
2/ The existing tailings dam poses unacceptable risks to the environment and downstream communities; the tailings dam requires further remediation, not massive expansion.
The tailings dam has continued to leak from beneath the toe of the dam at a rate of approx 1 litre/sec. The source of this seepage has not been identified.
The dam wall requires further intervention and remediation immediately to protect the downstream environment. Failure to address legacy issues of the existing tailings dam would be an abrogation of responsibility by the relevant State Government authorities.
3/ The expanded tailings dam will be built upon the seriously inadequate foundations of the original Benambra mine tailings dam. The proposed expansion of the tailings dam will exacerbate the risks the existing tailings dam poses to the environment and downstream communities which depend on the Tambo River for their water supply and should not proceed.
4/ The expansion of the tailings dam will also result in the immediate destruction of 20ha of vegetation including 0.36 ha of Montane Swamp, Montane Riparian Thicket EVC of high conservation value, 205 Large Old Trees and 320 Rare Banksia canei, and the possible destruction of rare Kiandra Greenhood, Montane Grass Trigger-plant and Alpine Spiny Crayfish. The original Benambra mine tailings dam was constructed on top of a 21ha Montane Swamp and destroyed 19ha of the site, this represented a loss of 47% of the total area of the community in Victoria. The Montane Swamp at the tailings dam site is a distinct sub-community. The offset for the 0.36ha of the remaining 2 ha Montane Swamp that will be destroyed is an area of Sub-Alpine Wet Heathland at Dinner Plain which does not have the exact same floristics.
5/ I am concerned that the draft Work Plan and any variations are not public documents.
In light of the extreme environmental risks of this project the draft Work Plan and any variations must be public document and open for comment.
6/ The Stockman Project Post Closure Deed has seriously underestimated the capital costs to manage and mitigate the environmental risks of the tailings dam for the next thousand years. The agreement signed between CopperChem and the State Government requires CopperChem to lodge a bank guarantee of only $5.7 million (adjusted for CPI every five years). There is no way this bond will cover the cost of major mitigation works over the thousand year life of the tailings dam. A bank guarantee of $5.7 mill is completely inadequate to deal with capital costs involved in remediating these control measures at such time as they inevitably fail.
Additionally, I am concerned that the rehabilitation bond will not be calculated until after the Work Plan is approved.
I believe that the risks of this project are serious and that these risks will continue into the indefinite future. It is in the best interests of the environment and the community that MIN006642 mining infrastructure licence is not granted.